Senior tax officials from over 20 countries recently met at a workshop to share experiences from the first year of country-by-country (CbC) reporting and explore how information can be used most effectively in the tax risk assessment of MNE groups.
The workshop was held on September 26-27, 2018, in Yangzhou, People’s Republic of China. The workshop was jointly organized by the OECD and the Chinese State Administration of Taxes, and included representatives of large MNE groups headquartered or with major operations in China and the Asia-Pacific region.
The workshop looked at different ways in which the information contained in a CbC report can be incorporated into improved tax risk assessment practices to give greater assurance to tax administrations and certainty to MNEs.
The workshop also considered lessons that can be learned from the implementation and operation of CbC reporting to date, from the perspective of jurisdictions and MNEs. Outcomes from these discussions will be incorporated into future work, including a review of the CbC reporting minimum standard, which will commence later this year for completion in 2020, the OECD noted.
CbC reporting is part of a three-tiered approach to transfer pricing documentation (along with “master” and “local” files) developed under base erosion and profit shifting Action 13. More than 70 countries have implemented comprehensive rules to require CbC reporting, with more jurisdictions in the process of implementing such a requirement.